Coleman v. Thompson, 501 U.S. 722 (1991)

In 1982, a Virginia jury found Roger Coleman guilty of the rape and murder of his sister-in-law. The trial judge sentenced Coleman to death. During his subsequent efforts to persuade Virginia’s courts to overturn his conviction, Coleman narrowly missed the deadline for filing an appeal with the Virginia Supreme Court—the papers arrived at the courthouse one day late. Because Coleman had violated the state’s procedural rules, the Virginia Supreme Court ordered Coleman’s appeal dismissed.

Coleman then filed a habeas corpus lawsuit in federal court, arguing that Virginia officials had violated his constitutional rights. By this time, the case was beginning to draw national attention, because Coleman’s attorneys were amassing evidence that indicated, in their judgment, that Coleman was innocent. When Coleman’s case reached the U.S. Supreme Court, however, the Court refused to consider Coleman’s legal claims. Overruling the Warren Court’s ruling in Fay v. Noia (1963), and building on rulings by the Burger Court in Francis v. Henderson (1976) and Wainwright v. Sykes (1977), the Rehnquist Court held that, ordinarily, a federal court must dismiss a state prisoner’s habeas lawsuit if that prisoner previously failed to follow all of the state’s procedural rules. Because Coleman had failed to meet one of Virginia’s filing deadlines, the Court dismissed his federal lawsuit. Coleman was executed on May 20, 1992, only days after appearing on the cover of Time magazine under the headline ‘‘This Man Might Be Innocent.’’ The legal rule announced in Coleman v. Thompson remains the rule today.

TODD E. PETTYS

References and Further Reading

• Hertz, Randy, and James S. Liebman. Federal Habeas Corpus Practice and Procedure. Charlottesville: LexisNexis, 4th ed., 2001.
• Tucker, John C. May God Have Mercy: A True Story of Crime and Punishment. New York: Dell Publishing, 1997.

Cases and Statutes Cited

• Fay v. Noia, 372 U.S. 391 (1963)
• Francis v. Henderson, 425 U.S. 536 (1976)
• Wainwright v. Sykes, 433 U.S. 72 (1977)

See also Capital Punishment; Capital Punishment: Execution of Innocents; Habeas Corpus: Modern History